Case Summary (G.R. No. 166883)
Procedural History
Petitioners sought a writ of habeas corpus before the Supreme Court on 11 August 2003, alleging that restrictive visitation regulations and other conditions at ISAFP Detention Center violated the detainees’ constitutional rights. On 12 August 2003 the Court issued the writ and referred the case to the Court of Appeals for factual hearing and decision. The petitioners and respondents appeared before the CA, which on 17 September 2003 dismissed the petition as meritless—holding that habeas corpus cannot be used to challenge valid indictments or conditions that do not directly restrain liberty.
Scope and Objective of Habeas Corpus
Habeas corpus under Rule 102, Secs. 1–8, is a limited remedy to test the lawfulness of physical detention. It does not substitute for appeal, nor does it serve as a general writ of error. Expanded applications permit relief only where a constitutional deprivation voids the entire confinement. The remedy does not lie to attack reasonable security regulations or to remedy noncustodial grievances.
Regulation of Visitation and Right to Counsel
RA 7438 § 4(b) guarantees private visits “at any hour of the day or, in urgent cases, of the night,” but expressly allows detention officers to undertake “reasonable measures to secure safety and prevent escape.” The ISAFP visiting hours (8 a.m.–5 p.m., with lunch breaks, and urgent‐case exceptions) are business-hour limits that ensure counsel access without jeopardizing facility security. The schedule did not impair face-to-face meetings or trial preparation; emergency deviations were permitted. These measures bear a reasonable relation to ISAFP’s legitimate security objectives.
Physical Conditions and Exercise Rights
The iron bars separating detainees from visitors, the boarding up of cell grills, and limited light or ventilation are restrictions inherent in lawful detention and rationally related to preventing contraband, escapes, or violence. Under Bell v. Wolfish and Block v. Rutherford (U.S. precedent), courts defer to administrators’ security judgments unless restrictions are arbitrary, excessive or intended as punishment. The CA found ISAFP conditions cleaner, less congested, and more secure than ordinary jails—factors affirmed by the Supreme Court.
Inspection and Reading of Detainees’ Mail
Opening and reading of unsealed letters—folded for convenience—and not marked confidential privileged mail, served the same contraband-screening purpose as inspecting sealed envelopes. U.S. and local jurisprudence recognize that detained persons lose reasonable expectations of privacy in non-privileged correspondence. If mail is marked as privileged legal communication, opening may occur only in the detainee’s presence and without reading
Case Syllabus (G.R. No. 166883)
Factual Background
- On 27 July 2003, 321 armed soldiers led by the detained junior officers seized Oakwood Premier Luxury Apartments in Makati City, disarmed security, planted explosives, and publicly called for the resignation of President Arroyo and key cabinet members.
- By evening the same day, the soldiers negotiated a voluntary surrender, defused the devices, and returned to barracks.
- On 31 July 2003, AFP Chief of Staff Gen. Abaya ordered the transfer of ten junior officers—among them petitioners Alejano, Faeldon, Gambala, Layug, Maestrecampo, and Trillanes—to ISAFP custody for investigation.
- On 1 August 2003, the Makati RTC Branch 61 filed Information for coup d’état under Article 134-A against the Oakwood participants (Crim. Case No. 03-2784) and issued Commitment Orders for Trillanes and Gambala to ISAFP.
- On 2 August 2003, Gen. Abaya directed all service commanders to detain participants except those already in ISAFP custody.
Procedural History
- Petitioners filed a petition for habeas corpus with the Supreme Court on 11 August 2003.
- On 12 August 2003, the Supreme Court issued a writ of habeas corpus, directed respondents to return the detainees on 18 August before the Court of Appeals, and referred the petition for raffle, hearing, and report by the appellate court.
- The detainees also secured a preliminary investigation order from the Makati RTC on the same date.
- On 18 August 2003, respondents filed their Return and Answer and produced the detainees before the Court of Appeals; memoranda were submitted on 28 August.
- On 17 September 2003, the Court of Appeals dismissed the petition (CA-G.R. SP No. 78545) but ordered Gen. Cabuay to honor the detainees’ visiting hours and exercise privileges under ISAFP SOP No. 0263-04.
- A Resolution of the Court of Appeals dated 13 November 2003 affirmed dismissal.
- Petitioners sought review under Rule 45 to nullify the CA Decision and Resolution.
Issues Presented
- Whether the Court of Appeals erred in reviewing a